Decapitalisation Rate for the 2026 Revaluation: business regulatory impact assessment

Business and regulatory impact assessment (BRIA) to consider the impact of the decapitalisation rate(s) for the 2026 revaluation.


Section 3: Costs, impacts and benefits

Quantified costs to businesses

Options 1 – 3

If the setting of decapitalisation rates causes the RV of properties valued using the Contractor’s method to increase in aggregate relative to those valued using other methods (in other words the share of Contractor’s method RV increasing relative to non-Contractor’s method RV), for a given poundage, this means the gross tax (before the value of reliefs are taken into account) burden on Contractor’s method properties will increase – and therefore that the share of gross tax burden on non-Contractors’ method properties will decrease (benefitting them in aggregate).

Conversely, if this causes the RV of properties valued using the Contractor’s method to decrease in aggregate relative to those valued using other methods (in other words the share of Contractor’s method RV decreasing relative to non-Contractor’s method RV), for a given poundage, this means, for given non-domestic rates, the gross tax (before the value of reliefs are taken into account) burden on Contractor’s method properties will increase as a proportion of the total.

Option 4 – Do not prescribe the rates in statute

As noted previously, if all else were equal, properties that see their RV decrease as a result of this would benefit and those that see it increase would incur a cost via their rates liability.

All respondents to the consultation in advance of the 2023 revaluation supported the proposal that the Scottish Government should continue to prescribe the decapitalisation rates on the basis it would provide certainty for assessors and ratepayers, and a greater degree of certainty in financial planning for taxpayers.

Failure to prescribe the rates in the past led to appeals that could take considerable time and expense to resolve.

Option 5 - Change the number of categories with different rates and/or their make-up

As noted previously, if all else were equal, properties that see their RV decrease as a result of this would benefit and those that see it increase would incur a cost.

There were mixed views expressed in the consultation responses about the benefits of changing the categories. One respondent for instance suggested that as their borrowing is at a similar rate to that provided to other public sector providers within health, education, etc. rather than the commercial rate, their properties should be valued using the lower decapitalisation rate, while another noted that they “would prefer to see the properties subject to one rate or the other defined for generically. In our opinion not-for-profit institutions and those which rely on public or private charitable funding should benefit from the lower decapitalisation rate, and ‘commercial’ operations pay the higher rate. Each ratepayer would then be able to claim the benefit of the lower rate if they fulfil the stated criteria.”

Table 1 shows the premises valued under the Contractor’s method as at April 2025*.

Table 1: Premises Valued under the Contractor’s Method as at April 2025, excluding zero-rated properties
Property class Property core description Number of premises Approx. RV (£m)
Education and Training School 2,638 430
Education and Training University 111 102
Education and Training College 122 46
Education and Training Other 200 23
Education and Training Day Nursery 272 6
Public Service Subjects Waste Water Treatment 1,011 44
Public Service Subjects Military Facility 200 59
Public Service Subjects Airfield 50 13
Public Service Subjects Prison 22 18
Public Service Subjects Police Station 186 14
Public Service Subjects Fire Station 314 13
Public Service Subjects Other 6,094 134
Health and Medical Hospital 203 162
Health and Medical Clinic 318 20
Health and Medical Surgery 153 4
Health and Medical Care Facilities 2,132 114
Health and Medical Other 145 15
Miscellaneous Industry (including factories, warehouses and stores) 526 196
Miscellaneous Petrochemical 107 107
Miscellaneous Leisure, Entertainment, Caravans and Holiday Sites 1,582 109
Miscellaneous Religious 5,108 57
Miscellaneous Cultural 556 39
Miscellaneous Statutory Undertaking 116 44
Miscellaneous Other 1,195 52
All All 23,361 1,823

Estimates are exclusive of a small amount of RV that is valued under hybrid methods, where part of the RV is valued under the Contractor’s Basis and part using another method.

Tables 2, 3.1, 3.2, 4.1, and 4.2 show the estimated impact, based on preliminary data provided by Scottish assessors on expected changes in the capital values of properties valued using the Contractor’s method.

Table 2: Summary of options
Option Rateable value (£m) Change in rateable value
Current (2025) 1,823 [blank]
Option 1 - keep at 2.90% and 4.60% 2,037 12%
Option 2 - increase to 4.18% and 6.15% 2,838 56%
Option 3 - match England at 2.60% and 4.40% 1,883 3%
Table 3.1: Rateable values at the discount rate (£m)
Property type Current Option 1 Option 2 Option 3
Education – total 602 674 972 604
Education – School 430 482 694 432
Education – University 102 115 165 103
Education – College 46 52 75 47
Education – Other 23 26 37 23
Healthcare – total 201 225 324 201
Healthcare – Hospital 162 181 261 162
Healthcare – Clinic 20 23 33 20
Healthcare – Surgery 4 4 6 4
Healthcare – Other 15 17 24 15
Day nursery 6 6 9 6
Care facilities 114 128 184 115
Religious 57 64 92 57
Table 3.2 Changes to rateable values at the discount rate
Property type Option 1 Option 2 Option 3
Education – total 12% 61% 0%
Education – School 12% 61% 0%
Education – University 12% 61% 0%
Education – College 12% 61% 0%
Education – Other 12% 61% 0%
Healthcare – total 12% 61% 0%
Healthcare – Hospital 12% 61% 0%
Healthcare – Clinic 12% 61% 0%
Healthcare – Surgery 12% 61% 0%
Healthcare – Other 12% 61% 0%
Day nursery 12% 61% 0%
Care facilities 12% 61% 0%
Religious 12% 61% 0%
Table 4.1: Rateable values at the headline rate (£m)
Property type Current Option 1 Option 2 Option 3
Public – total 236 268 358 256
Public – Waste water 44 48 64 46
Public – Airfield 13 14 19 14
Public – Prison 18 25 34 24
Public – Police station 14 16 21 15
Public – Fire station 13 15 20 14
Public – Other 134 150 201 144
Military facility 59 68 91 65
Industrial subjects 196 220 294 210
Petrochemical 107 116 155 111
Leisure etc. 109 120 161 115
Cultural 39 43 58 41
Statutory Undertaking 44 49 66 47
Other* 52 56 74 53
Table 4.2 Changes to rateable values at the headline rate
Property type Option 1 Option 2 Option 3
Public – total 11% 41% 7%
Public – Waste water 8% 44% 3%
Public – Airfield 10% 47% 5%
Public – Prison 40% 87% 34%
Public – Police station 12% 50% 7%
Public – Fire station 12% 50% 7%
Public – Other 12% 50% 7%
Military facility 15% 54% 10%
Industrial subjects 12% 50% 7%
Petrochemical 8% 44% 3%
Leisure etc. 10% 47% 5%
Cultural 12% 50% 7%
Statutory Undertaking 12% 50% 7%
Other* 11% 67% 4%

*The ‘Other’ category includes a range of around 1,200 diverse properties. The Assessors were able to provide estimates of changes to capital values for properties in this category accounting for £34 million of the £52 million total rateable value in 2025. For the remaining properties in this category, capital value was assumed to change in line with other properties valued using the Contractor’s Basis method.

It is estimated that Option 1 would lead to an increase in the RV of properties valued using the Contractor’s method of 12% at the next revaluation, Option 2 would lead to an estimated increase of 56%; and Option 3 to an increase of 3%.

Other impacts

There are no other expected impacts for businesses whose properties are valued using the Contractor’s method.

Scottish firms’ international competitiveness

The proposed policy is not expected to have an impact on Scottish businesses’ ability to compete internationally, or Scotland’s attractiveness as a destination for global capital investment, beyond the impact on rates liabilities as set out in the ‘Quantified costs to businesses’ section above.

Benefits to business

Maintaining the decapitalisation rates (Option 1) will benefit business valued under the Contractor’s method relative to Option 3 (increase the rates) in the form of lower rates liabilities. Further, prescribing decapitalisation rates offers certainty to business – prior to rates being prescribed, the rates were the object of appeals that could take considerable time and expense to resolve.

Small business impacts

The decapitalisation rates are set to keep the balance of tax burden stable and to avoid shifting costs from any one type of business to another, so no particular impact is expected on small businesses.

Properties valued using the contractors basis have a median rateable value more than double that of properties valued using comparative methods. This implies that they are less likely to be small businesses.

Investment

Given the rates are remaining the same, the proposed policy is expected to have a nil or close to nil impact on Scotland’s attractiveness as a place for global investment.

Workforce and Fair Work

The proposed policy is not related to workforce or fair work.

Climate change/Circular Economy

The proposed policy is not related to climate change/circular economy.

Competition Assessment

The proposed policy is not expected to have an impact on competition.

Consumer Duty

Non-domestic rates are a property tax, not a tax on consumers.

Contact

Email: ndr@gov.scot

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